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2 weeks ago | 
mondaq.com | Melissa Goldstein |Betty Santangelo |John Nowak |William J. Barbera
As investment advisers prepare to comply with the new anti-moneylaundering ("AML") program and reporting requirementseffective Jan. 1, 2026, it is instructive to review recentenforcement actions brought by the Securities and ExchangeCommission ("SEC").
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3 weeks ago | 
mondaq.com | Melissa Goldstein |Betty Santangelo |Michael Didiuk |Jessica Romano
Consistent with the US Department of the Treasury's ("Treasury") March 2, 2025, announcement, on March 21, 2025, Treasury's Financial Crimes Enforcement Network ("FinCEN") issued an interim final rule ("Interim Final Rule") narrowing the scope of reporting required under the Corporate Transparency Act and its implementing regulations (collectively, the "CTA")1 to exclude reporting from US entities and US persons.2 The Interim Final Rule is subject to comments but is effective immediately upon...
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1 month ago | 
mondaq.com | Melissa Goldstein |Betty Santangelo |Michael Didiuk |Jessica Romano
SR Schulte Roth & Zabel LLP More With a firm focus on private capital, Schulte Roth & Zabel comprises legal advisers and commercial problem-solvers who combine exceptional experience, industry insight, integrated intelligence and commercial creativity to help clients raise and invest assets and protect and expand their businesses.
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2 months ago | 
mondaq.com | Melissa Goldstein |Betty Santangelo |Michael Didiuk |Jessica Romano
On Feb.
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2 months ago | 
mondaq.com | Donald J Mosher |Kara Kuchar |Betty Santangelo |Melissa Goldstein
On Feb. 5, 2025, the Federal Deposit Insurance Corporation("FDIC") released a set of 175 documents1related to the FDIC's supervision of banks that engaged in, orsought to engage in activities related to cryptocurrency or digitalassets (broadly, "crypto"). In an accompanying statement,Acting FDIC Chairman Travis Hill stated, "The documents thatwe are releasing today show that requests [to pursue "crypto-or blockchain-related activities"] from ...
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2 months ago | 
mondaq.com | Melissa Goldstein |Betty Santangelo |Michael Didiuk |Jessica Romano
On Jan. 23, 2025, the US Supreme Court granted the request bythe government for a stay of the injunction issued by the USDistrict Court for the Eastern District of Texas in Texas TopCop Shop, Inc. v. McHenry that enjoined enforcement of theCorporate Transparency Act and its implementing regulation("Reporting Rule").1 However, on Jan.
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Jan 23, 2025 | 
mondaq.com | Donald J Mosher |Kara Kuchar |Betty Santangelo |Melissa Goldstein
On Jan. 10, 2025, the Consumer Financial Protection Bureau["CFPB") issued a proposed interpretive rule designed toclarify how the Electronic Fund Transfer Act ["EFTA") andits implementing regulation, Regulation E, apply to modern digitalpayment systems [the "Proposed Rule").1 TheProposed Rule aims to ensure that the protective measures ofRegulation E extend to consumers using digital wallets, paymentapps, gaming platforms, and digital assets such as stablecoins.
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Jan 22, 2025 | 
mondaq.com | Donald J Mosher |Kara Kuchar |Betty Santangelo |Melissa Goldstein
On Jan.
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Jan 16, 2025 | 
mondaq.com | Donald J Mosher |Kara Kuchar |Betty Santangelo |Melissa Goldstein
On Jan. 1, 2025, Massachusetts Governor Maura Healey signedH4840,1 also known as theMassachusetts Money Transmission Act ("MTA"), into law.2 The MTA, closelymodeled on the Money Transmission Modernization Act ("ModelLaw"), replaces the state's previous laws governing thesale of checks and money transmission by non-banks.
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Jan 9, 2025 | 
mondaq.com | Melissa Goldstein |Betty Santangelo |Michael Didiuk |Jessica Romano
On Dec. 26, 2024, the US Court of Appeals for the Fifth Circuitreinstated the nationwide preliminary injunction that enjoinsenforcement of the Corporate Transparency Act ("CTA") andits implementing regulation (31 C.F.R. §1010.380), includingthe filing deadlines thereunder.1 The FifthCircuit's Dec.
